Minnesota vs Ontario EPR: Rules Compared
Last verified
Minnesota and Ontario both run packaging EPR, but the rules differ. Ontario exempts only producers below the lower revenue floor, CA$2,000,000 against $2,000,000 in Minnesota. Minnesota has the lower weight floor, 907.2 kg against 1 tonne in Ontario. Both require producers to register. Both programmes set their first annual report for May 31.
Minnesota and Ontario side by side
4 of 9 rows have a verified figure on each side of Minnesota and Ontario; a cell reads “not yet published” when a side has none, and an exemption row reads “none recorded; see thresholds” when no exemption is on record.
| Measure | Minnesota | Ontario | Stricter |
|---|---|---|---|
| Registration duty | Required | Required | Same |
| Producer organisation | one producer responsibility organisation | more than one producer responsibility organisation | Not comparable |
| Lowest revenue exemption | $2,000,000 | CA$2,000,000 | Ontario |
| Lowest weight exemption | 907.2 kg | 1 tonne | Minnesota |
| First annual report date | May 31 | May 31 | Same |
| Published penalties | 1 published | not yet published | Not comparable |
| Report file | csv | csv | Not comparable |
| Paper fee, cheapest matched rate | not yet published | not yet published | Not comparable |
| Plastic fee, cheapest matched rate | not yet published | not yet published | Not comparable |
The lowest revenue exemption is $2,000,000 in Minnesota and CA$2,000,000 in Ontario ($1,430,820 at the Bank of Canada 2025 annual average rate). Ontario therefore reaches smaller sellers: a business with revenue between the two lines is exempt in Minnesota but still in scope in Ontario.
The lowest weight exemption is 907.2 kg of packaging in Minnesota and 1 tonne in Ontario, about 1.1 times as much in Ontario as in Minnesota. A seller whose packaging falls between the two lines is exempt in Ontario but counted in Minnesota.
Both programmes require a producer to register, in Minnesota and in Ontario.
The first annual report date is the same on both sides, May 31.
Who runs the programme in Minnesota and Ontario
Who collects and who the producer files with, in Minnesota and then Ontario.
| Aspect | Minnesota | Ontario |
|---|---|---|
| Regime | Minnesota packaging EPR law, Minnesota Statutes sections 115A.144 to 115A.1463 | Full producer responsibility for Blue Box material (packaging, paper products, packaging-like products) under the Blue Box Regulation |
| Regulator | Minnesota Pollution Control Agency | Resource Productivity and Recovery Authority (RPRA) |
| Producers obligated | Yes | Yes |
| Registration | Required, Producer joins a PRO; the PRO registers with the MPCA | Required, RPRA Registry |
| Producer organisation | one producer responsibility organisation: Circular Action Alliance; membership required | more than one producer responsibility organisation; membership optional |
| Transfer of responsibility | not yet published | Allowed |
| Revenue counted as | not yet published | regional revenue, CAD, calendar year |
| Who counts as the producer | primary: manufacturer, brand licensee, brand owner, importer | other: brand owner, importer, seller, online marketplace; primary: brand owner, importer, seller, online marketplace; secondary: brand owner, importer, seller, online marketplace; service: seller; shipping: brand owner, importer, seller, online marketplace; tertiary: brand owner, importer, seller, online marketplace |
The two programmes are organised differently. Minnesota uses one producer responsibility organisation; Ontario uses more than one producer responsibility organisation. For a seller in both, that usually means two different counterparties, two different sign-up routes and two different sets of terms to read before the first report is due.
What Minnesota and Ontario cover, side by side
Each row below is one published feature of the two programmes; a cell reads “not yet published” when Minnesota or Ontario has no verified entry for it in the dataset.
| Aspect | Minnesota | Ontario |
|---|---|---|
| Materials covered | packaging, paper products | paper, glass, metal, plastic, other |
| Product classes covered | packaging, paper | primary packaging, secondary packaging, shipment packaging, other |
| Excluded from scope | exempt materials | producers under revenue exemption, newspaper producers for collection management and promotion |
| Sales channels addressed | physical retail, remote sale, other distribution | retail, wholesale, online, online marketplace |
| Producer duty: primary packaging | manufacturer; licensee; brand_owner; importer | brand_owner; importer; seller; marketplace |
| Exemption 1 | A de minimis producer introduced under one ton or earned under $2,000,000 in global gross revenue in its most recent fiscal year. | Producers with gross annual Ontario revenue under 2,000,000 dollars are exempt from all producer requirements. |
| Producer duty: secondary packaging | not yet published | brand_owner; importer; seller; marketplace |
| Producer duty: tertiary packaging | not yet published | brand_owner; importer; seller; marketplace |
| Producer duty: shipping packaging | not yet published | brand_owner; importer; seller; marketplace |
| Producer duty: service packaging | not yet published | seller |
| Producer duty: other packaging | not yet published | brand_owner; importer; seller; marketplace |
| Reporting categories | not yet published | 7, material category |
| Published targets | not yet published | paper_management_requirement 80 by 2027-12-31; rigid_plastic_management_requirement 50 by 2027-12-31; flexible_plastic_management_requirement 10 by 2027-12-31; glass_management_requirement 75 by 2027-12-31; metal_management_requirement 67 by 2027-12-31; beverage_container_management_requirement 75 by 2027-12-31 |
| Exemption 2 | not yet published | Producers above the revenue level but below the per-category supply weights are exempt from collection, management and promotion and education, but still register and report. |
| Exemption 3 | not yet published | Producers whose newspaper supply is more than 70 percent of their total Blue Box weight are exempt from collection, management and promotion and education. |
Thresholds and exemptions in Minnesota and Ontario
Every verified threshold Minnesota and Ontario publish, as each states it.
| Place | Measure | Amount | Effect | Basis as published |
|---|---|---|---|---|
| Minnesota | packaging tonnage | 1 short ton | exempt below | covered material introduced, most recent fiscal year |
| Minnesota | revenue | $2,000,000 | exempt below | global gross revenue, most recent fiscal year |
| Ontario | revenue | CA$2,000,000 | exempt below | gross annual Ontario revenue from products and services |
| Ontario | packaging tonnage | 9 tonnes | exempt below | paper supplied in Ontario per year (9,000 kg) |
| Ontario | packaging tonnage | 2 tonnes | exempt below | rigid plastic supplied in Ontario per year (2,000 kg) |
| Ontario | packaging tonnage | 2 tonnes | exempt below | flexible plastic supplied in Ontario per year (2,000 kg) |
| Ontario | packaging tonnage | 1 tonne | exempt below | glass supplied in Ontario per year (1,000 kg) |
| Ontario | packaging tonnage | 1 tonne | exempt below | metal supplied in Ontario per year (1,000 kg) |
| Ontario | packaging tonnage | 1 tonne | exempt below | beverage containers supplied in Ontario per year (1,000 kg) |
Minnesota exemption: A de minimis producer introduced under one ton or earned under $2,000,000 in global gross revenue in its most recent fiscal year. It does not have to be applied for.
Ontario exemption: Producers with gross annual Ontario revenue under 2,000,000 dollars are exempt from all producer requirements. It does not have to be applied for.
Ontario exemption: Producers above the revenue level but below the per-category supply weights are exempt from collection, management and promotion and education, but still register and report. It does not have to be applied for.
Ontario exemption: Producers whose newspaper supply is more than 70 percent of their total Blue Box weight are exempt from collection, management and promotion and education. It does not have to be applied for.
Read the basis column first: the same amount can exempt a producer in one programme and only simplify its report in another.
The lowest revenue exemption is $2,000,000 in Minnesota and CA$2,000,000 in Ontario ($1,430,820 at the Bank of Canada 2025 annual average rate). Ontario therefore reaches smaller sellers: a business with revenue between the two lines is exempt in Minnesota but still in scope in Ontario.
The lowest weight exemption is 907.2 kg of packaging in Minnesota and 1 tonne in Ontario, about 1.1 times as much in Ontario as in Minnesota. A seller whose packaging falls between the two lines is exempt in Ontario but counted in Minnesota.
Fees per kilogram for shared materials
Neither Minnesota nor Ontario has a verified per-kilogram fee schedule in the dataset yet. Until both sides publish per-kilogram rates for the same material class, a fee comparison between Minnesota and Ontario would mean inventing a figure, and this page does not do that.
Deadlines in Minnesota and Ontario
Each verified date, with the period it covers when one is given.
| Place | Kind | Date | Covers |
|---|---|---|---|
| Minnesota | registration | July 1, 2026 | not yet published |
| Minnesota | report | May 31, 2026 | not yet published |
| Minnesota | other | December 31, 2026 | not yet published |
| Minnesota | other | October 1, 2028 | not yet published |
| Minnesota | payment | February 1, 2029 | not yet published |
| Minnesota | payment | February 1, 2030 | not yet published |
| Minnesota | payment | February 1, 2031 | not yet published |
| Ontario | report | May 31, 2026 | calendar year 2025 |
| Ontario | report | May 31, 2026 | calendar year 2025 |
The first annual report date is the same on both sides, May 31.
Penalties in Minnesota and Ontario
What each side has published; a side without an amount says so.
Minnesota penalty for violation of sections 115A.144 to 115A.1463: up to $25,000 per day.
Report formats in Minnesota and Ontario
How the report file for Minnesota compares with the one for Ontario.
| Aspect | Minnesota | Ontario |
|---|---|---|
| Layout | Minnesota interim producer supply report by material class 2026-09-29 (interim, built from CAA guidance) | Ontario Blue Box supply report (working layout) Working layout, sources reviewed 2026-11-04 |
| Recipient | Circular Action Alliance (Minnesota PRO) | Resource Productivity and Recovery Authority (RPRA) |
| How it is submitted | CAA producer portal. The customer signs in and submits. | RPRA Registry (online). The customer signs in and enters or submits. |
| File type | csv | csv |
| Encoding | utf-8 | utf-8 |
| Delimiter | , | , |
| Decimal separator | . | |
| Columns | 4 | 4 |
| Required columns | 4 of 4 | 4 of 4 |
| Weight unit | lb | kg |
| Period basis | calendar year | calendar year |
The two layouts share a file type and a delimiter, but each programme names its own columns and categories, so one file cannot be sent to both programmes. Each report is built from the same underlying measurements and exported separately.
Which to plan for first, Minnesota or Ontario
Check the exemption thresholds before anything else. Ontario reaches smaller sellers than Minnesota, so a seller that is exempt in Minnesota may still have to register in Ontario.
Questions about comparing these two programmes
Is Minnesota or Ontario stricter on packaging EPR?
Ontario exempts only producers below the lower revenue floor, CA$2,000,000 against $2,000,000 in Minnesota. Minnesota has the lower weight floor, 907.2 kg against 1 tonne in Ontario. Both require producers to register. Both programmes set their first annual report for May 31.
Do I register in both Minnesota and Ontario?
Minnesota requires producers to register. Ontario requires producers to register.
How do the fees per kilogram compare in Minnesota and Ontario?
The dataset does not hold per-kilogram rates for the same material class on both sides, so this page does not compare fees.
Which deadline comes first, Minnesota or Ontario?
The first annual report date is the same on both sides, May 31.
How these figures are made
Sources
- revisor.mn.gov: 115A.1441 retrieved
Original wording: requirements under sections 115A.144 to 115A.1463
Original wording: "Producer" means the following person responsible for compliance with requirements
Original wording: introduced less than one ton of covered material into this state
Original wording: earned global gross revenues of less than $2,000,000
Original wording: "De minimis producer" means a person that in their most recent fiscal year
Original wording: Packaging does not include exempt materials.
- circularactionalliance.org: minnesota retrieved
Original wording: the Minnesota Pollution Control Agency (MPCA) confirmed CAA’s registration to implement the state’s EPR program.
Original wording: Producers must be a member of a PRO that is registered with MPCA by July 1, 2025.
Original wording: CAA requires producers to provide simplified reporting by May 31, 2026
Original wording: December 31, 2026 Full Needs Assessment Due.
- web.archive.org retrieved
Original wording: the MPCA confirmed Circular Action Alliance (CAA) — a 501(c)(3) nonprofit, producer-led organization — as Minnesota’s initial PRO.
- revisor.mn.gov: 115A.1443 retrieved
Original wording: The producer responsibility organization must register with the commissioner by July 1, 2026, and each January 1 thereafter
- revisor.mn.gov: 115A.1451 retrieved
Original wording: By October 1, 2028, and every five years thereafter, a producer responsibility organization must submit a stewardship plan
- revisor.mn.gov: 115A.1455 retrieved
Original wording: no less than 50 percent of the net cost by February 1, 2029
Original wording: no less than 75 percent of the net cost by February 1, 2030
Original wording: no less than 90 percent of the net cost by February 1, 2031, and each year thereafter
- revisor.mn.gov: 115A.1462 retrieved
Original wording: civil penalty not to exceed $25,000 per day of violation
- rpra.ca: regulation retrieved
Original wording: Blue Box producers became fully accountable and financially responsible for collecting and recycling their materials when consumers discard them.
- rpra.ca: producers retrieved
Original wording: Unless otherwise stated, all information must be submitted through RPRA’s registry.
Original wording: if they supply Blue Box material (packaging, paper products or packaging-like products) comprised of paper, glass, metal or plastic
Original wording: Within 30 days of supplying obligated Blue Box materials in Ontario
Original wording: PROs operate in a competitive market, and producers can choose the PRO (or PROs) they want to work with.
Original wording: Producers have the choice of working with one or more producer responsibility organizations (PROs) registered with RPRA
Original wording: Any producer whose gross annual Ontario revenue from products and services is less than $2,000,000 is exempt from all producer requirements under the regulation.
Original wording: if the retailer who would be the producer is a marketplace seller, the marketplace facilitator is the obligated producer
Original wording: is exempt from all producer requirements under the regulation.
Original wording: Paper 9,000
Original wording: Rigid plastic 2,000
Original wording: Flexible plastic 2,000
Original wording: Glass 1,000
Original wording: Metal 1,000
Original wording: Beverage containers 1,000
Original wording: Any producer who meets the exemption must keep any records that demonstrate its gross annual Ontario revenue is less than $2,000,000
Original wording: the producer is required to register and report.
Original wording: newspaper must account for more than 70% of their total weight of Blue Box materials supplied to consumers in Ontario in a calendar year.
Original wording: Deadline: Supply data must be submitted by May 31 of each year.
Original wording: Deadline: Performance reporting is due May 31 of each year.
Original wording: Under the Blue Box Regulation, consumers are individuals who use a product and its packaging for personal, family or household purposes.
Original wording: beverage container, glass, flexible plastic, rigid plastic, metal, paper, and certified compostable products and packaging
Original wording: Management requirement = A × B
- Bank of Canada, FXAUSDCAD (annual average 2025) retrieved
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